Durham was sentenced to 50 years in prison in 2012 for running a Ponzi scheme through his Akron, Ohio business Fair Finance. Durham defrauded an estimated 5,000 investors and used the money to support his luxurious lifestyle and other business ventures.

The SEC had asked Durham to repay more than $200 million. Judge Magnus-Stinson argued that the amount wasn't equal to the amount Durham swindled from his investors, and instead ruled that he should pay $130,000 for each of his 10 criminal convictions.